GFSC Thematic Review of AML BRAs – check sheet to consider sufficiency and suitability
03/01/2023
The GFSC issued [15th December 2022] its report on the thematic review of business risk assessments ON money laundering and terrorist financing
- The thematic was undertaken to assess more than 100 licensed and registered firms [across all sectors] and how well firms identified and assessed these risks to their businesses.
- The results were positive, demonstrating that most Business Risk Assessments met Bailiwick's regulatory requirements.
CONSIDERATION OF THE SUFFICIENCY AND SUITABILITY OF YOUR BRA
The GFSC noted that
- The quality of BRAs was considerably higher where firms had drawn on their firm-specific MI,
- With most of the BRAs assessed as not suitable or sufficient largely because they lacked detail and were overly generic.
- And as evidenced by a proportion of firms' BRAs, further improvement in the identification and recording of TF risks will assist in Bailiwick's collective efforts to counter the ever-present risk.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.